GR 185711; (August, 2009) (Digest)
G.R. No. 185711; August 24, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. REYNALDO SANZ LABOA, Accused-Appellant.
FACTS
On June 26, 2001, nine-year-old AAA was instructed by her father to go home and cook. After gathering firewood, she fell asleep on a bench inside her house. The appellant, Reynaldo Sanz Laboa, was hired by AAA’s mother to construct a divider and was working outside. He entered the house, awakened AAA, and proceeded to remove her shorts and underwear. He placed saliva on her vagina, went on top of her, and inserted his penis, causing her pain. AAA tried to resist but was overpowered.
The crime was interrupted when Ariel Estabillo arrived to return a borrowed tool. Ariel witnessed the appellant on top of AAA with his pants zipper open and AAA naked from the waist down. Ariel struck the appellant with the tool, prompting the appellant to flee. AAA, crying, was brought to her parents, who reported the incident to the authorities. A medical examination revealed fresh hymenal lacerations consistent with attempted sexual penetration.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of the appellant for the crime of rape.
RULING
Yes, the conviction is affirmed. The Supreme Court upheld the findings of the lower courts, emphasizing that the credibility of the victim’s testimony is paramount in rape cases. AAA’s account was straightforward, consistent, and credible. Her minority at the time of the incident (nine years old) made her testimony even more credible, as it is presumed that a child of such tender years would not fabricate a tale of sexual abuse. Her testimony was corroborated by the eyewitness account of Ariel Estabillo, who caught the appellant in the act, and by the medical findings of fresh hymenal lacerations.
The Court rejected the appellant’s defense of denial, which is inherently weak when juxtaposed with the positive and categorical identification by the victim. The appellant’s claim that Ariel merely misinterpreted his actions was unconvincing. The elements of rape under Article 266-A(1)(d) of the Revised Penal Code were sufficiently proven: carnal knowledge with a woman under twelve years of age. Since the victim was under twelve, force, intimidation, or consent becomes immaterial. The penalty of reclusion perpetua was properly imposed. The Court also affirmed the award of civil indemnity, moral damages, and exemplary damages, the latter justified by the victim’s minority to serve as a public deterrent.